Privacy policy
In accordance with the principles of lawfulness, fairness and transparency set out in Regulation (EU) 2016/679, the General Data Protection Regulation (GDPR), we provide this Privacy Policy in order to inform you about the processing of your personal data.
1. Who is responsible for processing your data?
| Data controller | AXON PARTNERS GROUP, S.A. |
| Tax ID (NIF) | A-86505914 |
| Registered office | Calle Sagasta, No. 18, 3rd floor, 28004 Madrid (Spain) |
| marketing@axonpartnersgroup.com | |
| Telephone | +34 91 310 28 94 |
| Data Protection Officer | axonlegal@axonpartnersgroup.com or dpolegal@grupoadaptalia.es |
2. For what purposes do we process your personal data?
At AXON PARTNERS GROUP, S.A. we process the personal data you provide to us for the following purposes, depending on your relationship with us:
| Data subjects | Purposes of processing |
| Prospective clients | Managing the pre-contractual relationship, dealing with information requests, responding to enquiries, preparing commercial proposals and following up business opportunities. |
| Clients | Managing the contractual, administrative, financial and commercial relationship arising from the provision of our services. |
| Suppliers and collaborators | Managing the contractual, administrative, accounting and invoicing relationship. |
| Candidates | Managing recruitment processes and assessing candidacies for future vacancies. |
| Website users | Managing website browsing, analysing use of the website through cookies, and dealing with enquiries submitted via the contact form. |
| Subscribers | Managing the sending of newsletters, corporate information and commercial communications where prior consent has been given. |
3. What is the legal basis for processing your data?
The legal basis for processing will depend on your relationship with AXON:
| Data subjects | Legal basis |
| Prospective clients | Article 6(1)(b) GDPR (application of pre-contractual measures) and Article 6(1)(f) GDPR (legitimate interest in responding to enquiries and dealing with requests). |
| Clients | Article 6(1)(b) GDPR (performance of a contract). |
| Suppliers | Article 6(1)(b) GDPR (performance of a contract). |
| Candidates | Article 6(1)(b) GDPR (application of pre-contractual measures) and, where applicable, Article 6(1)(a) GDPR (consent to retain the CV for future recruitment processes). |
| Website users | Article 6(1)(f) GDPR (legitimate interest in dealing with enquiries) and Article 6(1)(a) GDPR (consent for non-essential cookies). |
| Commercial communications | Article 6(1)(a) GDPR (consent of the data subject) or, where applicable, Article 21.2 of Law 34/2002 on Information Society Services and Electronic Commerce. |
The data requested is adequate, relevant and limited to what is necessary for each purpose. Refusal to provide it may prevent us from providing the requested service.
4. How long will we keep your data?
Personal data will be kept for as long as necessary to fulfil the purpose for which it was collected and, thereafter, for the periods established by applicable law.
5. Who will your data be shared with?
Your personal data may be shared where necessary to comply with legal obligations or to properly provide our services.
In particular, it may be shared with:
• Banks, for the management of payments and collections.
• Public authorities, courts and tribunals, where there is a legal obligation to do so.
• Technology providers, web hosting providers, email services and other data processors that provide services to AXON under the corresponding data processing agreement.
• Companies belonging to the AXON Group, where such disclosure is necessary for the provision of services, internal administrative management, or where another legal basis permits it.
Personal data will never be sold to third parties.
6. Are any international data transfers carried out?
As a general rule, no international transfers of data are made outside the European Economic Area. However, certain technology providers used by AXON, such as Google, may carry out international transfers arising from the use of cookies or other digital services. Such transfers will only take place where the user has given their consent, and will be carried out in accordance with the safeguards set out in the GDPR, including, where applicable, the provider’s adherence to the EU-U.S. Data Privacy Framework or other legally recognised mechanisms. Further information is available in our Cookie Policy.
7. What are your rights?
You may exercise the following rights at any time:
• Right of access.
• Right of rectification.
• Right of erasure.
• Right to object.
• Right to restriction of processing.
• Right to data portability.
• Right not to be subject to automated individual decision-making, including profiling, where applicable.
You may exercise these rights by written request sent to AXON’s registered office, or by email to the address provided for data protection matters. Furthermore, if you consider that the processing of your data does not comply with applicable law, you may lodge a complaint with the Spanish Data Protection Agency (www.aepd.es).
8. Can you withdraw your consent?
Where processing of your data is based on your consent, you may withdraw it at any time, without affecting the lawfulness of processing carried out prior to such withdrawal.
9. Complaints
If you consider that your personal data is not being processed correctly, or that your rights have not been properly addressed, you may lodge a complaint with the Spanish Data Protection Agency. Further information is available at www.aepd.es.
10. Data security
AXON has implemented appropriate technical and organisational measures to ensure a level of security appropriate to the risk, in order to protect personal data against alteration, loss, unauthorised processing or access, in accordance with applicable law. However, users should be aware that security measures on the Internet are not entirely impregnable.
11. Keeping your data up to date
The data subject warrants that the data provided is truthful, accurate and up to date, and undertakes to notify AXON of any changes.
12. Confidentiality
All AXON personnel involved in any stage of the processing of personal data are bound by a duty of confidentiality and the professional secrecy obligations established by law. Personal data will only be processed for the purposes described in this Privacy Policy and will not be disclosed to third parties, except in cases provided for by applicable law or where necessary for the provision of contracted services.